DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Claim Rejections - 35 USC § 112
The following is a quotation of 35 U.S.C. 112(b):
(b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention.
The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph:
The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention.
Claims 3-4 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention.
The term “about” in claim 3 is a relative term which renders the claim indefinite. The term “about” is not defined by the claim, the specification does not provide a standard for ascertaining the requisite degree, and one of ordinary skill in the art would not be reasonably apprised of the scope of the invention. It would be unclear to a PHOSITA how close the tolerances must be to the claimed tolerance range to meet the limitations.
The term “firmly” in claim 4 is a relative term which renders the claim indefinite. The term “firmly” is not defined by the claim, the specification does not provide a standard for ascertaining the requisite degree, and one of ordinary skill in the art would not be reasonably apprised of the scope of the invention. It would be unclear to a PHOSITA how firmly the stopper would need to hold the board in place to meet the limitations.
Claim Rejections - 35 USC § 102
The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
A person shall be entitled to a patent unless –
(a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention.
(a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention.
Claims 1, 5, and 8 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Belanger (US Patent No. 5258889).
Regarding claim 1, Belanger discloses an apparatus for securing a board (circuit board 14) to an enclosure (housing 12), comprising: an adaptable clip (tab 16) operably coupled to a lid (cover 10) of the enclosure (12) and configured to move from an unflexed configuration (see Figure 2) for receiving the board (14) to a flexed configuration (see Figure 3) for securing the board to the enclosure (12).
Regarding claim 5, Belanger discloses the apparatus of claim 1, and further discloses wherein the adaptable clip (16) is made from at least one of metal or plastic (see col. 1, ln. 60-67).
Regarding claim 8, Belanger discloses the apparatus of claim 1, and further discloses wherein the board (14) is at least one of a printed circuit board (see col. 2) or printed circuit board assembly.
Alternatively, claim 1 is rejected under 35 U.S.C. 102(a)(1) as being anticipated by Suzuki (US Patent No. 6373710).
Regarding claim 1, Suzuki discloses an apparatus for securing a board (Figure 4, circuit board 15) to an enclosure (case 16), comprising: an adaptable clip (tool 23) operably coupled to a lid (cover 22) of the enclosure (21) and configured to move from an unflexed configuration (unengaged configuration) for receiving the board (15) to a flexed configuration (engaged configuration) for securing the board to the enclosure (21; see col. 8, ln. 1-28).
Claim Rejections - 35 USC § 103
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
Claim 2 is rejected under 35 U.S.C. 103 as being unpatentable over Suzuki (US Patent No. 6373710) in view of Lin (US Publication No. 2008/0169391).
Regarding claim 2, Suzuki discloses the apparatus of claim 1, wherein the adaptable clip (23) is coupled to the lid (22) of the enclosure (21; via engagement between 24 and 25) 23) to the lid (22).
Suzuki does not teach wherein the adaptable clip is coupled to the lid via an interference fit using a flexible snap.
However, Lin teaches wherein an adaptable clip (fixing component 20) is coupled to a lid (bracket 16) via an interference fit using a flexible snap (engagement between protruding piece 46 and hole 28).
It would have been prima facie obvious to one of ordinary skill in the art before the effective file date of the claimed invention to have substituted the threaded connection of Suzuki for the snap-fit connection of Lin according to know methods to yield the predictable results of connecting a clip to a lid (see Figure 1 in Lin; see Figure 4 in Suzuki).
Claim 3 is rejected under 35 U.S.C. 103 as being unpatentable over Belanger (US Patent No. 5258889).
Regarding claim 3 (as best understood), Belanger discloses the apparatus of claim 1, and further suggests wherein the adaptable clip is configured to flex to accommodate tolerances of the board from about -0.4 mm to about +0.4 mm (see Figures 2-3 and col. 2).
Because the apparatus of the claimed invention has similar structure and proportion to the apparatus of Belanger, the stated limitation is held to be merely a selection of optimal working parameters established through routine experimentation, and thus obvious to a person of ordinary skill in the art. MPEP § 2144.05(II)(A); In re Williams, 36 F.2d 436, 438 (CCPA 1929) ("It is a settled principle of law that a mere carrying forward of an original patented conception involving only change of form, proportions, or degree, or the substitution of equivalents doing the same thing as the original invention, by substantially the same means, is not such an invention as will sustain a patent, even though the changes of the kind may produce better results than prior inventions."). A person of ordinary skill in the art would have had a reasonable expectation of success to formulate the claimed range because doing so would have allowed the clip to accommodate a range of circuit boards (see col. 2 in Belanger).
Claim 4 is rejected under 35 U.S.C. 103 as being unpatentable over Belanger (US Patent No. 5258889) in view of Ebrom (US Publication No. 2017/0142835).
Regarding claim 4 (as best understood), Belanger discloses the apparatus of claim 1, but does not explicitly disclose wherein the lid comprises a stopper that is configured to control a flexibility of the adaptable clip, hold the board firmly in place to the enclosure, and prevent the adaptable clip from over flexing and breaking when the board is being connected to the enclosure.
However, Ebrom teaches wherein a lid (backer 505) comprises a stopper (edges of backer 505) that is configured to control a flexibility of the adaptable clip (flexible members 505), hold the board (PCB 512) firmly in place to the enclosure (fascia 105), and prevent the adaptable clip (510) from over flexing and breaking when the board (512) is being connected to the enclosure (105).
Because Belanger also discloses edges of the lid contacting the enclosure, it would have been prima facie obvious to one of ordinary skill in the art before the effective file date of the claimed invention to have configured the edges of the lid in Belanger to contact the enclosure, as taught in Ebrom. Doing so would have allowed the lid to regulate the flexibility of the clip (see Paragraph [0050] and Figures 5-6 in Ebrom).
Claims 6-7 are rejected under 35 U.S.C. 103 as being unpatentable over Belanger (US Patent No. 5258889) in view of Kim (US Publication No. 2023/0217585).
Regarding claim 6, Belanger discloses the apparatus of claim 1, but does not explicitly disclose wherein the board comprises electronics used for one or more components in an energy management system.
However, Kim teaches wherein a board (Figure 2, PCB 200) comprises electronics used for one or more components (MLCC 208, capacitor 210) in an energy management system (see Paragraphs [0025]-[0026]).
It would have been prima facie obvious to one of ordinary skill in the art before the effective file date of the claimed invention to have substituted the PCB of Belanger for the PCB of Kim, according to know methods to yield the predictable results of storing a PCB within a housing configured to hold down the PCB (see Figure 2 and Paragraphs [0032]-[0035] in Kim; see Figures 1-2 and col. 2 in Belanger). Alternatively, it would have also been prima facie obvious to one of ordinary skill in the art before the effective file date of the claimed invention to have combined the energy management components of Kim to the PCB of Belanger. Doing so would have provided the PCB with power control functions (see Paragraphs [0025]-[0026]).
Regarding claim 7, Belanger in view of Kim teaches the apparatus of claim 6, and further teaches (in Kim) wherein the one or more components (208, 210) in the energy management system (see Figure 2) comprises at least one of photovoltaics, microinverters, storage systems (208 and 210 being energy storage systems), or main panels.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. US Patent/Publication Nos. 4713633 5388030 5397856 6381136 6445588 6545352 20060187643 20110011998 8077476 8330894 also teaches elements of the claimed device
Any inquiry concerning this communication or earlier communications from the examiner should be directed to GAGE STEPHEN CRUM whose telephone number is (571)272-3373. The examiner can normally be reached Monday - Friday 8:00 am - 5:00 pm.
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/GAGE CRUM/Primary Examiner, Art Unit 2841
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